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Monday, September 17, 2007

FCC meets the heavy hitters

On Sept. 13th, the FCC got a visit from AT&T, Verizon, Embarq, Sprint and Qwest. I can't keep up with all the mergers and splits among telcos, but I'm sure that covers most of the phones in the country.

So they came bearing a bunch of ideas for reforming the E-Rate. I was prepared to hate the ideas, as I have in the past, but I kind of like them. Here's my scorecard:

E-Rate accounts
Description: Instead of having applicants (or service providers) invoice USAC, once funding is approved, it goes into an account that applicants can use to pay bills.
My Assessment: It's outside the box, which I like, but the idea's no good. It's a cash flow nightmare: USAC would have to pay a huge amount up front, and some applicants would have to return funding at the end of the year (which they wouldn't do, so USAC would have to chase down that money).

Short-circuit BEAR payment loop
: Send BEAR reimbursement checks to applicants, instead of ricocheting all checks off the service providers.
My Assessment: Yes, yes, yes.

Require separate 471s
: Require that Priority 2 funding requests be on a separate 471 from Priority 1 requests.
My Assessment: This suggestion isn't bad, and was made for all the right reasons, but I hate new requirements. And the whole problem would go away if PIA would just get comfy with "As Yet Unfunded."

Form 471C
: Create a separate Form 471 for the continuation of multi-year contracts, kind of like the 1040-EZ.
My Assessment: I'm on the fence about this one. Multi-year contracts are a little tough, but a whole new form? I'd rather see smart pre-population of the 471: you click a button on the online form, and all your FRNs from the previous year pop in, and any multi-year contracts you submitted come in nicely.

Close 470 window early
: Make 12/31 the deadline for submitting the 470.
My Assessment: No. The idea is to give applicants more time after the 470 to file the 471, but let's get real: most applicants need one day to file the 471, and it will be the last day they're allowed to file. And if you take a step back, one of the big-picture problems with this program is that it forces applicants to make technology decisions 6-18 months before the technology will be implemented. Let's not make that any worse by pushing deadlines further away from the implementation date.

Early ESL
Description: Release the Eligible Services List by June 1 every year.
My Assessment: If I could turn my E-Rate dreams into lucid dreams, this would be one of the first.

The final score: 2-3-1. But there were two lovely proposals, and none that I hated.

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